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Cybersecurity › Policies and Procedures › Investment Adviser

Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk... more +
Follow this channel for advisories on one of the biggest threats to businesses today. Read a morning brief of fresh guidance and commentary by leading lawyers on security, privacy, risk management, global regulations, data protection, leaks, hacking, cyber insurance, compliance, HIPAA, and every other aspect of cybersecurity of import to corporate readers right now.   less -
SEC Compliance Consultants, Inc. (SEC³)

Lessons From 2024: Tips for Private Fund Managers

SEC Compliance Consultants, Inc. (SEC³) on

As we look back on the SEC’s actions in 2024, we wanted to share our thoughts on lessons learned that we believe will carry through to 2025....more

Snell & Wilmer

SEC Division of Examinations Priorities for 2025: Examinations Will Prioritize New Rules for Form PF and Regulation S-P, Fiduciary...

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On October 21, 2024, the Division of Examinations (the “Division”) of the U.S. Securities and Exchange Commission (the “SEC”) issued its annual examination priorities for fiscal year 2025. As with its 2024 examination...more

Latham & Watkins LLP

SEC Imposes New Cybersecurity Requirements on BrokerDealers, Investment Companies, Registered Investment Advisers, and Transfer...

Latham & Watkins LLP on

Covered institutions will need to review their cybersecurity and incident response policies and procedures ahead of the applicable compliance deadline. The Securities and Exchange Commission (SEC) recently adopted...more

SEC Compliance Consultants, Inc. (SEC³)

Regulatory Roundup for May 2024

SEC Compliance Consultants, Inc. (SEC³) on

SEC DROPS NEW REQUIREMENT FOR INCIDENT RESPONSE PROGRAMS, PROPOSAL FOR RIAS TO ADOPT CIP, SEC EXAMS SHARES MARKETING RULE FAILURES, RIA SLAMMED FOR FAILING TO RETAIN TEXTS, AND SEC WINS ON SHADOW TRADING THEORY - Welcome to...more

Foley Hoag LLP - Security, Privacy and the...

SEC Revamps and Enhances Data Protections with Amendments to Regulation S-P

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The Securities and Exchange Commission (“SEC”) has announced the adoption of amendments to Regulation S-P (“Amendments”) to modernize and enhance the rules that govern the treatment of consumers’ nonpublic personal...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Eversheds Sutherland (US) LLP on

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Akin Gump Strauss Hauer & Feld LLP

New Privacy and Cybersecurity Obligations for Private Fund Sponsors and Managers

Akin Gump Strauss Hauer & Feld LLP on

Last week, the Securities and Exchange Commission imposed expanded privacy and cybersecurity obligations on fund managers and sponsors registered with the SEC as investment advisers. While many registered investment advisers...more

Proskauer - The Capital Commitment

Cybersecurity Continues to be a Focal Point for Regulators in 2024

Proskauer - The Capital Commitment on

The SEC’s new and proposed rules on cybersecurity and cyber-incident reporting will have a dual impact on private investment advisers and funds. First, the proposal by the SEC will impose cybersecurity related...more

Davis Wright Tremaine LLP

Investment Adviser Expectations in 2024

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Like many other industries, Registered Investment Advisers ("RIAs") have dealt with significant regulatory, technological, and systemic change in recent years. Compared to FINRA-regulated entities, RIAs often face these...more

Miller Canfield

2024 Regulatory Update for Investment Advisers

Miller Canfield on

In 2023, the Securities and Exchange Commission issued various proposed rules on regulatory changes that will affect SEC-registered investment advisers (RIAs). Since these rules are likely to be put into effect, RIAs should...more

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

Skadden, Arps, Slate, Meagher & Flom LLP on

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Lowenstein Sandler LLP

SEC’s 2024 Examination Priorities for Investment Advisers

Lowenstein Sandler LLP on

The U.S. Securities and Exchange Commission (SEC) Division of Examinations (the Division) recently released its annual Examination Priorities for fiscal year 2024 (the Report). The Report underlines the Division’s focus on...more

Seward & Kissel LLP

FTC Imposes New Data Breach Notification Requirements

Seward & Kissel LLP on

On October 27, 2023, the Federal Trade Commission (the “FTC”) adopted a final rule (“Final Rule”) to amend the Standards for Safeguarding Customer Information (the “Safeguards Rule”). Among other things, the Final Rule will...more

Akin Gump Strauss Hauer & Feld LLP

SEC Releases Risk Alert on EXAMS Process

Akin Gump Strauss Hauer & Feld LLP on

Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents* I. Introduction - The SEC-registered investment adviser (“adviser”) population is large and diverse, ranging from global asset managers...more

BakerHostetler

The SEC's Proposed Cybersecurity Rules: Regulatory Delay Does Not Bless Standing By

BakerHostetler on

The SEC’s Cybersecurity Proposals - The SEC has proposed four rules designed to address cybersecurity risk and management, including incident reporting by public companies....more

Morrison & Foerster LLP

The SEC Expands Focus on Cybersecurity Risk to Include Registered Advisers, Broker‑Dealers, and other Market Participants

Morrison & Foerster LLP on

Last month, the SEC took a big step toward strengthening the cybersecurity of financial systems by proposing regulations that, taken together, will require registered investments advisers, broker‑dealers, and all national...more

Proskauer - The Capital Commitment

SEC Revisits Regulation S-P After Twenty Years of Innovation to Information Technology

Proskauer - The Capital Commitment on

On March 15, 2023, the U.S. Securities and Exchange Commission (“SEC”) released its proposal to amend Regulation S-P: Privacy of Consumer Financial Information and Safeguarding Customer Information (the “Proposed...more

Lowenstein Sandler LLP

Investment Advisers, Broker-Dealers, and Other Financial Industry Participants Take Note: SEC Demonstrates Commitment to...

Lowenstein Sandler LLP on

On March 15, 2023, the Securities and Exchange Commission (“SEC”) issued three releases proposing (i) amendments to Regulation S-P (“Regulation S-P Proposal”)1, (ii) amendments to Regulation SCI (“Regulation SCI Proposal”)2,...more

Goodwin

SEC Proposes Changes to Reg S-P to Enhance Protection of Customer Information

Goodwin on

In this Weekly Roundup Issue. The Securities and Exchange Commission (SEC) proposed changes to Reg S-P to enhance protection of customer information, and reopened the comment period on proposed cybersecurity rules and...more

Holland & Knight LLP

Changing of the Guard? SEC Proposes Significant Amendments to the Safeguards Rule

Holland & Knight LLP on

The SEC continued its recent onslaught of proposed cybersecurity rules in mid-March with three new proposals covering a litany of entities, including investment advisers, broker-dealers, investment companies, clearing...more

Moore & Van Allen PLLC

The Devil Really is in the Details: The SEC Proposed Rule on Cybersecurity Risk Management for Investment Advisors, Registered...

Moore & Van Allen PLLC on

Late last month the Securities and Exchange Commission (“SEC”) charged JP Morgan, UBS and Trade Station with violations of Regulation S-ID based on a range of  inadequacies in their identity theft red flag policies and...more

Ballard Spahr LLP

New SEC Proposed Cyber Rules Signal Concern About Systemic Risk

Ballard Spahr LLP on

After many years of signaling potential expansion of cybersecurity rules, the Securities and Exchange Commission (SEC) has issued in the past month two new sets of proposed rules governing cybersecurity.  The more recent set...more

Cooley LLP

SEC votes to propose new rules for cybersecurity disclosure and incident reporting [UPDATED]

Cooley LLP on

[This post revises and updates my earlier post primarily to reflect the contents of the proposing release.] - At an open meeting last week, the SEC voted, three to one, to propose regulations “to enhance and standardize...more

K&L Gates LLP

SEC Proposes Cybersecurity Risk Management Rules for Investment Advisers and Funds

K&L Gates LLP on

On 9 February 2022, the U.S. Securities and Exchange Commission (the SEC) proposed new rules and amendments to existing rules (together, the Proposed Rules) addressing cybersecurity risk management under the Investment...more

Holland & Knight LLP

SEC Proposes Substantial New Cybersecurity Requirements for Investment Advisers and Companies

Holland & Knight LLP on

Following U.S. Securities and Exchange Commission (SEC) Chairman Gary Gensler's recent speech directing the agency to expand cybersecurity requirements on regulated entities, the SEC on Feb. 9, 2022, voted to propose new...more

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